Public Consultation 2017

The Marine Management Organisation (MMO) is currently holding a third public consultation about Dover Harbour Board’s application to dredge aggregate from the Goodwin Sands. The consultation runs until midnight on 28th September 2017.

The application has recently been altered and the MMO are seeking public comments about the additional information.

We have put together some information that should help you make comments to them, including a campaign background, the new documents which include responses to the 2016 consultation and some suggested points you could consider in your personal submission.

Background

In May 2016 Dover Harbour Board applied to the Marine Management Organisation (MMO) for a licence to dredge 2.5 million m3 of sand from the Goodwin Sands to use for landfill and construction of their new Dover Western docks. They have focussed on the Goodwins as being their cheapest option.

In January 2017 DHB appointed Volker Stein Boskalis Westminster (VSBW) as their main contractors for phases 1 and 2. In April 2017, Westminster Gravels Ltd, part of the Boskalis Westminster group, was granted a licence to dredge a new area in the Outer Thames Estuary called Area 501. This is made up of two parts, 501/1 and 501/2 and is licensed to extract 45 million tonnes of aggregate over 15 years, with a maximum of 6 million tonnes per year.

In August 2017, DHB announced they will be extracting 500,000 m3 of aggregate from this new area 501 as they need it for immediate works, thereby reducing the amount of sand they wish to take from the Goodwins by a corresponding amount of 500,000 m3.

Historical Dredging

DHB repeatedly state that the Goodwin Sands are a designated dredge site. This is incorrect. They are not. However, the Goodwin Sands have previously been dredged for the Dover Hoverport, Dover Eastern Docks, Ramsgate Port and the Channel Tunnel. This was in the previous decade before environmental awareness brought about the current regulatory framework for dredging licences.

In 1976 the Deal Boatmen and Dover District Council objected to the first dredging licence. Their concerns were allayed by the reassurance that this would be ‘for one project only’ and would not be ‘the thin end of the wedge for the further taking of sand’ (KM Archives 1976 and 1979). However, 5 licences were issued between 1976 and 1999. All further local objections were overruled by DHB and Ministry for Agriculture, Fisheries and Food (MAFF).

Allegation

Dover Harbour Board claims that not to be allowed to dredge the Goodwin Sands will cost the town of Dover £1/2 bn in lost revenue from jobs, regeneration, tourism and new business (Advert EKM 2nd August 2017).

Goodwin Sands v Area 501

Reliance upon the Goodwins

The development is not reliant upon dredging specifically from the Goodwin Sands. There are plenty of commercial dredging sites available in the East English Channel and the Thames Estuary. These are all within the industry norm in terms of distance from site to wharf (e.g. Hastings to Dover is about 40 nm, Hastings to Tilbury about 70 nm).

Contingency Plan

It appears that DHB does not have a contingency plan if the Goodwins are not available. This is hard to believe for a project of such national importance. Neither do DHB appear to have a contingency budget for sourcing aggregate elsewhere. Why not?

Cost of alternative marine aggregate

The Scoping Report published by Royal Haskoning DHV in July 2016 gives two differing figures for obtaining marine aggregate from elsewhere; £6M and £20M. Whichever of these is correct (and it has been impossible to verify them) there is therefore no reason for DHB to claim that the town will lose £500M should they not be allowed to dredge the Goodwins.

Volume of sand required

DHB state they need to take only 0.22% of Goodwins sand or ‘an egg cup from a tonne of sand’. This is misleading. They wish to take the top 1.95m off the surface of a 3.9 km2 area of the South Goodwins sandbank. This is not an insignificant amount in such a small area and represents 13% of the top 1.95m of the total surface area of the sands (30 km2). DHB are playing with statistics; they want to take a larger proportion of a smaller area, they are saying they want to take it from the Goodwins giving the impression that it’s from the whole site, this is untrue, it’s a specific site they want to extract from.

Environmental Impact Assessment

Democratic Process

The dredging licence application process is a democratic one involving one or more public consultations. In this instance the public have already been consulted twice and they have objected. They do not expect to be intimidated and harassed almost to the point of blackmail by unfounded allegations that not being allowed to dredge the Goodwins will cost Dovorians jobs and future regeneration.

Geophysical surveys

Dover Harbour Board were requested by Historic England to undertake a magnetometer survey of the proposed dredging zone as part of their licence application. This was done during May 2017 together with repeat side scan sonar, multi beam echo sounder and sub bottom profiler surveys.

Dover Harbour Board have agreed that specialist company 3H Consulting Ltd could independently analyse the raw data from these results as a control measure and the report submitted to the MMO. This is currently in progress.

Expert Support

Goodwin Sands SOS have done their research and the campaign is based on true facts. They are supported by a network of specialist advisors from the fields of maritime archaeology, marine conservation, coastal processes and the fishing industry.

Underwater Cultural Heritage

Historic England’s concerns about military aircraft crash sites and dredging

By 2008, Historic England had become so concerned about the high number of remains from military aircraft crash sites being accidentally dredged up in licenced dredging sites, that they commissioned Wessex Archaeology to carry out a scoping report. This revealed:

The seabed off the south & east coasts of England has the highest density of aircraft crash sites in the world.

The majority of these lie in unknown locations.

There are particular problems in identifying these crash sites prior to dredging.

It’s difficult to rely on geophysical surveys alone to identify air crash sites.

There were more finds discovered than were recorded – under-reporting was the norm on account of the ensuing bureaucracy and the cost of investigation, recovery and preservation.

Wessex are now consultants to DHB, but the situation on our coastline regarding archaeological wrecks has not changed since 2008

‘There is a high potential for the remains of crashed aircraft on the Goodwin Sands. There are two records of crashed aircraft, however this is unlikely to be a realistic reflection of the potential of aircraft to be present’.This is repeated in various forms throughout the EIA that DHB had commissioned by its advisors Wessex Archaeology and RHDHV.

Protection of Military Remains Act 1986

It is illegal to disturb a military air crash site without obtaining a licence from the Ministry of Defence.
However, the locations of these sites need to be known first. Wessex Archaeology is not
recommending further investigation of the any of the anomalies lying in the centre of the new
reduced dredging zone (especially the large cluster right in the middle), which could easily be a
military air crash site if it is not a shipwreck. This means that DHB could potentially be laying
themselves open to the possibility of desecrating one or more military air crash sites and therefore
breaking the law.

Kent Battle of Britain Museum

This museum collated a list for Goodwin Sands SOS and the Ministry of Defence of 60 aircraft and 74 aircrew from Britain, Germany & Poland who crashed into the Channel in the Goodwin Sands area between May and November 1940 alone, never to be recovered.

‘Archaeologically Extraordinary’ Goodwin Sands

In 2015 Historic England again commissioned Wessex Archaeology to undertake a case study of the Goodwin Sands. This study described the Goodwins as ‘archaeologically extraordinary’ because they hold the highest density of maritime heritage assets in UK waters, including designated ones and wrecks have a reputation of being very well preserved. The current excavation project of the Rooswijk which sank in 1740 is a prime example of this.

BBC4 Dr Sam Willis ‘Shipwrecks; Home Waters & High Seas’ July 2017

In the opening ten minutes of this documentary Dr Sam Willis describes the fascinating history of the Goodwin Sands explaining that they hold the highest density of shipwrecks in the world.

Marine Conservation and Coastal Erosion

Recommended Marine Conservation Zone

The Goodwin Sands recommended Marine Conservation Zone (rMCZ) is an area of 276.91 km2 of which the Goodwin Sands are the dominant feature. Five broad-scale habitats are features designated for protection, including 155 km2 of subtidal sand. It is this sand, which is the target aggregate and is where fish breed, their eggs are laid and the ecological food-chain establishes itself. However, because the MCZ has not yet been fully designated, the MMO cannot insist that DHB carry out a full MCZ assessment as part of their dredging licence application. The MMO have confirmed to both Kent Wildlife Trust and GWS SOS that ‘they will take the impacts of the proposed activity (dredging) on the features of the rMCZ into consideration when coming to their decision’ though it is unclear what guidelines will be followed. GWS SOS have asked for clarification and await an answer.

Environment Agency and coastal flooding

The beaches at Deal and Kingsdown are in continual need of recharging. The beach at Oldstairs Bay in Kingsdown suffers chronic erosion. Photographs from 1906 to 1962 show it to be twice as large as it is today, remaining fairly constant in size. Between 1962 and 2016 the beach receded rapidly with spring tides frequently bringing sea water up close to properties on Wellington Parade at Kingsdown. Although the harbour arms at Folkestone and Dover are recognised as factors affecting beach erosion at Kingsdown and Deal, the accelerated erosion clearly began after the previous rounds of dredging. This has not been investigated by either Royal Haskoning DHV, Dover District Council or the Environment Agency.

GWS SOS has spent the past year challenging the EA on this who refused to listen until a formal complaint was lodged. A number of questions raised by GWS SOS have now been acknowledged as being legitimate and the EA have asked for a meeting with DHB to discuss them. However, DHB are avoiding rescheduling this meeting and at the time of writing no date has been set. The EA are a statutory consultee to the MMO.

GWS SOS has also challenged Dover District Council who did not have any objections to the proposed dredging from a planning perspective. They have repeatedly ignored our concerns about coastal erosion saying they have complete faith in the conclusion reached from computer modelling tests done by H R Wallingford of ‘no residual impact’. The EA has confirmed to GWS SOS that computer models should only be used as a tool / guide and cannot reliably predict future wave behaviour. DDC has confirmed it has allocated £1.5M to recharge the beach at Oldstairs Bay over the next five years.

Seal Colony

The Zoological Society of London have very real concerns about the impact that dredging will have on the colony of 500 grey and harbour seals, which spend 7-12 hours of each day hauled out on the Goodwins. DHB say they will avoid dredging at sensitive times of year but since these clash with the proposed dredging timetable (May to August) it is difficult to see how this can be done. British Divers Marine Life Rescue are also very concerned.

Fishing industry

The Thanet Fishermen’s Association was consulted at great length prior to the publication of the EIA but all their concerns and objections were completely ignored in the EIA.

The Future

Setting a precedent

The Crown Estate Mineral Resources Guide clearly includes the Goodwin Sands. Over the past year the campaign has been sent six articles about the world scarcity of sand. There is therefore a very real danger that should a dredging licence be granted now, a dangerous precedent will be set which will open the doors for the further taking of sand in the future.

Documents

This is the new information that has been provided in response to MMO’s letter of 20th December 2016 and the public representations from the last consultation:

We only have until 28th September 2017 to send our objections about the proposed dredging to the Marine Management Organisation (MMO). Please write something personal and straight from the heart, including any of the points mentioned below that you feel most strongly about as well as anything else you feel is important.

HERITAGE
IN 2015, Wessex Archaeology (WA), Dover Harbour Board’s (DHB) consultants, described the Goodwin Sands as ‘archaeologically extraordinary’. This is because they have the highest density of maritime heritage assets in UK waters. The repeated geophysical surveys conducted in May ‘17 identified a total of 305 anomalies scattered through out the proposed dredging area, a significant increase from just 6 in July ’15. These could be either parts of shipwrecks or military air crash sites, yet WA has not recommended further investigation of any of them. Why not?

WA have recommended 25m radius buffer zones around each unidentified object, which has forced DHB to reduce the width of the dredging zone to as little as 200m in some places. However, 23 significant anomalies still remain in the reduced dredging zone; avoiding these will make it look like a Swiss cheese! The sand pedestals created around these unidentified sites will become very unstable and eventually collapse, thereby damaging the objects they were meant to protect. One particular cluster of anomalies could potentially be part of a crashed military aircraft or even a wooden shipwreck, yet no investigations have been recommended.

These anomalies could represent the final resting places of any of the thousands of mariners and scores of WWII aircrew who have perished on the treacherous Sands.

SEALS
The dredging timetable for 2018 and 2019 is May to August and June to July respectively, which coincides exactly with the breeding season of the grey and harbour seals. A 1.5 km buffer zone around their haul-out site is intended to protect the seals but vibration and noise travel far further underwater and the seals will still be disturbed and their behaviour seriously affected.

FISHING
DHB claim that the fishing grounds of the Goodwin Sands are of little importance and that more prolific areas of fishing are to be found outside them. Local fishermen are unanimous in telling us otherwise and however small their business, their livelihoods will undoubtedly be dramatically affected by the dredging.

COASTAL EROSION
The MMO and the Environment Agency are taking our concerns about the protection the Goodwin Sands offer our vulnerable foreshore very seriously. DHB are not. Chronic coastal erosion is on-going and we must ensure that these uncertainties are properly addressed and not ignored by DHB or their contractors. Contrary to popular belief, the Sands do not regenerate themselves; they move but they do not breed!

ALTERNATIVE DREDGING SITE – AREA 501
Due to immediate pressures, DHB have arranged to source 500,000 m3, (750,000 tonnes) of aggregate from a newly licenced area in the Outer Thames Estuary. However, DHB still wish to take 2 million m3 (3 million tonnes) from the Goodwins, which is still a significant amount! Area 501 lies 41 nautical miles from Dover, well within the industry norm in terms of distance from dredge site to wharf. It is geotechnically suitable, with no restrictions imposed upon it and is licenced to produce 6 million tonnes of aggregate a year for 15 years starting summer 2017.

Obtaining aggregate from Area 501 will also not require under-resourced Government Agencies, such as Historic England, the MMO, Natural England and the Environment Agency, having to continually monitor and report upon mid and post dredge surveys well into the future. It will also mean that on-board archaeological, explosives and marine mammal observers will not be needed, at a saving to DHB.

ECONOMICS
DHB cite the extra cost of obtaining aggregate from Area 501 as the main factor against it. However, the public cannot be held responsible for DHB’s inadequate planning, which omitted to include a contingency budget. Despite rampant scaremongering, the fundamental infrastructure of Dover Western Docks Revival is not financially at risk if DHB cannot dredge the Goodwins Sands.

How to Respond to the MMO

You can make responses during this third consultation regarding only the new information detailed in the Documents section above.

In all cases you mustquote the case reference number MLA/2016/00227 and include either an email or postal address they can use for correspondence relating to the representation or objection. The MMO will pass copies of any objections or representations they receive to Dover Harbour Board.

Abbreviations

MMO = Marine Management Organisation

DHB = Dover Harbour Board

DWDR = Dover Western Docks Revival.

RHDHV = Royal HaskoningDHV. These are the contractors for DHB who compiled the environmental impact assessment (EIA).

VSBW = Volker Stein Boskalis Westminster. Project managers for DWDR.

WA = Wessex Archaeology. DHB’s consultant archaeologists.

Remember to respond before the consultation closes on the 28th September 2017.